In April, MyComplianceOffice co-hosted a Webinar with Robin Singh titled, "Common Pitfalls while Implementing an Anti-Corruption Program." Attendees of the Webinar learned that anti-corruption regulation and enforcement is a growing area of global concern. As part of follow up to this program, Robin has kindly shared with the MCO blog his top 10 essentials of a highly effective anti-corruption framework
1. Proportionate Procedures
Procedures that exist to prevent any act of bribery should be proportionate to the risk. Moreover, policies should be accessible, clear, practical, enforced and effectively implemented.
2. Commitment of top management
Top management should be thoroughly committed towards confrontation of bribery across the company. Management should work towards creating a culture where accepting or giving bribes must be discouraged.
3. Risk assessment
While assessing risks, both internal and external risks should be considered. Regular risk assessments should be performed and results of the same should be documented.
4. Due diligence
The anti-bribery approach has to be risk-based and proportionate. Persistent efforts should be given by all parties who are providing services for the business.
Procedures as well as policies should be understood and embedded. Training should be in proportion to risks and customized according to specific needs.
6. Internal audits
Internal audits should be conducted according to documented procedure to check the effectiveness of anti-bribery procedures.
7. Monitoring and review
Evaluation is essential to find out how effective the procedures for bribery prevention are in an organization and make changes wherever necessary.
It is a question that is defined differently and offers different level of confidentiality depending on the institution that is developing the Anti-corruption framework (such as non-governmental or governmental institutions can offer). Depending on the type of reporting and the degree of confidentiality an organization can proactively propose their assistance as intermediaries in addressing such offences.
9. Investigation & Discipline
The framework should define an organization’s zero tolerance towards such crimes and the type of discipline level an organization is willing to go to set a lesson and ingrain a culture of integrity.
You must have proper training for your framework to be effective. Without it, forget about getting compliance. Train and carry out refresher trainings to make your program a success.
To learn more about what Compliance Officers can do to ensure that their firm's framework is free from these loopholes or pitfalls, visit the recordings from the Webinar now available here; 'Common Pitfalls While Implementing an Anti-Corruption Program'.
Download the slides from this webinar here.
About the Author
Robin Singh is a certified compliance professional and a fraud examiner. He has worked in the Big 5 accounting firms such as Deloitte and Protiviti. He carries a strong experience in Compliance and Ethics, Fraud Investigations, developing anti-fraud frameworks, setting up Ethics and compliance programs across jurisdictions such as Singapore, the Middle East and India. He has ideated forensic tools / solutions for his selected fortune, 500 clients. He is a keen writer on the subject of ethics and compliance and has published articles across electronic and physical media. He currently works for the Abu Dhabi government authority which governs all healthcare providers where he manages the activities of Compliance and Fraud Control Department.
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